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ITAT Delhi Remands FTS Taxability of Software & SaaS Receipts for Fresh Examination
Case Law Details
- Case Name
- SFDC Ireland Ltd Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Delhi
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SFDC Ireland Ltd Vs DCIT (ITAT Delhi)
The assessee, a tax resident of Ireland and successor to Tableau International, Unlimited Company, Ireland, challenged the final assessment order passed under sections 143(3) read with 144C(13) of the Income-tax Act for AY 2020-21, whereby receipts of ₹73,41,69,869 from Indian customers were taxed as Fees for Technical Services (FTS) under section 115A of the Act and Article 12 of the India-Ireland Double Taxation Avoidance Agreement (DTAA). The receipts comprised revenue from supply of non-customised shrink-wrapped/off-the-shelf/electro...
